Rating: Partially Compliant
Antigua and Barbuda’s implementation of the AEOI Standard is partially compliant with respect to exchanging the information effectively in practice and in a timely manner. More specifically, while Antigua and Barbuda is meeting expectations with respect to sorting, preparing and validating the information (SR 2.4) and providing corrections, amendments or additions to the information (SR 2.9), there are significant issues with respect to Antigua and Barbuda correctly transmitting the information in a timely manner (SRs 2.5 – 2.8). Antigua and Barbuda should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).
Findings:
Feedback from Antigua and Barbuda’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Antigua and Barbuda and therefore with respect to Antigua and Barbuda’s implementation of these requirements. More generally, one of Antigua and Barbuda’s exchange partners reported rejecting more than 50% of the files received due to the technical requirements not being met. This is a low amount when compared to other jurisdictions.
Based on these findings it was concluded that, Antigua and Barbuda is fully meeting expectations in relation to sorting, preparing and validating the information. Antigua and Barbuda is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.
Recommendations:
No recommendations made.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Antigua and Barbuda linked to the CTS.
Based on these findings it was concluded that Antigua and Barbuda is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Antigua and Barbuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Antigua and Barbuda’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Antigua and Barbuda and therefore with respect to Antigua and Barbuda’s implementation of this requirement.
Based on these findings it was concluded that Antigua and Barbuda is fully meeting expectations in relation to exchanging the information in a timely manner. Antigua and Barbuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Antigua and Barbuda’s exchange partners did not raise any concerns with respect to Antigua and Barbuda’s use of the agreed transmission methods and therefore with Antigua and Barbuda’s implementation of this requirement.
Based on these findings it was concluded that Antigua and Barbuda is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Antigua and Barbuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
23 exchange partners highlighted delays in the sending of status messages by Antigua and Barbuda, representing 27% of its partners. This represents a very high proportion of partners. Antigua and Barbuda has still not yet sent all of the status messages due to be sent in 2021, as well as some that were due to be sent in prior years.
Based on these findings it was concluded that Antigua and Barbuda is not meeting expectations in relation to the receipt of the information. More specifically, fundamental issues have been identified, including with respect to sending status messages on receipt of files. Antigua and Barbuda should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
Antigua and Barbuda should ensure it sends status messages to all of its exchange partners in a timely manner.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Antigua and Barbuda appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Antigua and Barbuda’s exchange partners and therefore with respect to Antigua and Barbuda’s implementation of these requirements.
Based on these findings it was concluded that Antigua and Barbuda appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Antigua and Barbuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.